Comments on: Ways that TRI can Drive Environmental Improvementhttp://blog.epa.gov/metalminingblog/2010/05/statement-1/
Fri, 28 May 2010 14:21:05 +0000hourly1https://wordpress.org/?v=4.4.1By: Southeast Alaska Conservation Councilhttp://blog.epa.gov/metalminingblog/2010/05/statement-1/comment-page-1/#comment-73
Wed, 25 Nov 2009 16:59:53 +0000http://blog.epa.gov/metalminingblog/?p=30#comment-73The rational for the TRI list under Community Right to Know extends backwards from evaluating environmental assessment risks to process development design to prevent or minimize toxic discharges from industries. The TRI list provides information that allows industry, regulators, and the public to appraise waste generating processes throughout the waste generating cycle to push for development of environmentally sound processes. Integration of environmental impacts and resource consumption into core business operations results in improvements of efficiency that minimize energy and water use, and waste generation. This drives environmental improvement through cost-based incentives separate from permit fees and fines.

The information being gathered under TRI reporting may, or may not have immediate applications to process development, or demonstrate clear impacts to the environment, but often the value of such data bases is not evident until some future date. No one at the time suspected at the time that birth and death records collected in the 1300’s could be utilized to predict flu outbreaks in the 21 century.

SEACC fully supports EPA’s move to strengthen the TRI process and move toward full accountability of toxins entering the environment. This move is necessary to fully implement the Public Trust Doctrine.

]]>By: Andy Wildenberghttp://blog.epa.gov/metalminingblog/2010/05/statement-1/comment-page-1/#comment-69
Tue, 24 Nov 2009 18:30:39 +0000http://blog.epa.gov/metalminingblog/?p=30#comment-69People have a right to know what mining operations are introducing into the environment and how much they’re introducing. The TRI provides a starting point for this knowledge. TRI information allows people to assess the risk to which they expose themselves and their families when they move into an area. It helps public health professionals set appropriate screening mechanisms to protect the area downwind/downstream from the mining source. It lets hunters and fishers decide whether their quarry are safe to eat. It lets conscientious consumers far away from mines determine what environmental impacts they’ve indirectly caused through the consumption of products derived from mining.

Mining can not occur with some environmental impact, so any decision related to mining has to balance the benefit of the mine against its negative environmental impacts. A TRI provides a concrete list of impacts to consider, and most importantly it allows regulators to compare what other similar mining operations have promised in their permits versus what they have delivered once their operations are live. This provides additional accountability in the permitting process.

Finally, a strong TRI forces industry to prove that they are doing what they promised in their permits by actively conducting searches for contaminates. The industry is far more capable of doing this than consumers or governments, and it’s only fair that such surveys are a basic cost of doing business. Estimates are worthless, because there are always ways to estimate any reality into compliance. At the end of the day, if you claim you’re emitting below a particular level, you need to measure that you’re emitting below a particular level. There have been too many sites where estimates were dramatically at odds with reality, and when that inaccuracy is discovered, all that is left is for the company to fold and the operation to become yet another superfund consumer bailout of corporate mining.

]]>By: Brian Turnbaugh, OMB Watchhttp://blog.epa.gov/metalminingblog/2010/05/statement-1/comment-page-1/#comment-66
Tue, 24 Nov 2009 17:21:05 +0000http://blog.epa.gov/metalminingblog/?p=30#comment-66TRI data have been used consistently since the program’s inception to drive down releases of toxic chemicals. If the metal mining industry claims that TRI reporting does not “drive environmental improvement within this industry as it is currently implemented,” then it is clear there is not enough reporting. The public disclosure of toxic pollution is crucial to understanding impacts and risks to public and environmental health. The data inform public policies to protect ecosystems and the species dependent on them. TRI data can be used to prevent mining sites from joining the long list of mines that are now Superfund sites, costing billions of dollars in remediation. Citizens have a right to know about the types and quantities of toxic chemicals they are exposed to by mining activities, and how mining activities impact surface and ground water and the dust blowing over their homes and farms. If the metals mining industry admits it has failed to use the data it supplies to the TRI program to innovate and improve processes and reduce toxic releases, then stronger regulations are needed to drive those improvements. TRI data will inform those regulations.
]]>By: Justin Hayes, Idaho Conservation Leaguehttp://blog.epa.gov/metalminingblog/2010/05/statement-1/comment-page-1/#comment-61
Tue, 24 Nov 2009 01:39:01 +0000http://blog.epa.gov/metalminingblog/?p=30#comment-61TRI reporting does lead to pollutant reductions.

My experience is that companies do not like the negative PR associated with disclosing large discharges/emissions and take steps to reduce discharges to avoid the negative implications.

TRI is a very valuable tool – it lets communities know who is polluting what and it shames polluters into making reductions the my not otherwise be “required” to make.

]]>By: John K. Thomas, Texas A&M Universityhttp://blog.epa.gov/metalminingblog/2010/05/statement-1/comment-page-1/#comment-16
Fri, 16 Oct 2009 15:50:21 +0000http://blog.epa.gov/metalminingblog/?p=30#comment-16Could the industry be more specific about what data does not correlate with environmental and health impacts and what “its driving environmental improvement” means? The EPA has identified hundreds of chemicals and compounds that are toxic in specific ways. If these chemicals are present in mining wastes in toxic amounts then the human and environmental impacts are a ticking time bomb, waiting for the industry’s deniability in public discourse. As for “driving environmental improvement”, what initiative has the industry taken to drive environmental improvement? There needs to be less figure pointing and more collaboration.
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